FATF Mutual Evaluation Scorecard

United Kingdom

The UK has a very good understanding of its ML and TF risks as reflected it its NRAs. The UK also showed significant improvement with its national coordination and cooperation both AML/CFT policy and operational levels since its 2009 evaluation.
Proactive investigation and prosecution is evident in TF activities and demonstrate strong public and private partnerships and information sharing. The same goes for ML activity, however, these cases generally take years to prosecute and convict. With this, it is unclear as of the 2018 MER if there is alignment with UK’s threats, risk profile and national AML/CFT policies.
The UK has been a world leader in designating terrorists at the United Nations (UN) and European Union (EU) level, as well as in its corporate transparency.
Significant ML risks come from overseas, particularly from other financial centres, and cross-border banking.

The UK has demonstrated progress related to R13, resulting to an upgraded re-rate in 2022. In the 2018 MER, there was lack of application of enhanced due diligence (EDD) measures for correspondent banking within the European Economic Area (EEA). To address this, the UK amended the definition of third country or outside jurisdictions in the Money Laundering Regulations (MLR), effectively making EDD measures mandatory for correspondent banking and other similar relationships.
The other main opportunity identified in the 2018 MER was R29, and concerns related to the operational independence of the UK Financial Intelligence Unit (FIU) and its limited ability to conduct operational and strategic analysis. The UK has made progress to address this through the SARs Reform Programme. This warranted an expansion in staff and technology. However, the expansion remains insufficient due to the size of its financial sector, the growth of SARs filed in the last couple of years, and the corresponding changes from IT systems. R29 thus remain at the same rating.
Despite some setbacks, the UK was considered as compliant to new FATF requirements, retaining a majority of its “Compliant” and “Largely Compliant” ratings.